We appreciate that the discussion draft of the proposed legislation maintains a separate federal regulator for credit unions – a core value for us. Nevertheless, we do have concerns with several provisions of the legislation, including the title that creates a Consumer Financial Protection Agency.

As we have said before, credit unions agree that consumers of financial products—especially consumers of products and services provided by currently unregulated entities—need greater protections. Credit unions, owned by the members they serve in a cooperative structure, have long advocated strong consumer protection. Credit unions focus their resources on service to their member/owners – a unique relationship among financial institutions that means the credit union operates in a consumer-friendly manner. Additional regulatory burden only takes away from continued and effective service.

Under the Dodd bill, credit unions will face additional examinations and supervision by the proposed CFPA, which is also tasked to do the same for for-profit, investor-owned financial institutions. Credit unions are unique, and need a unique regulator in all aspects of examination and supervision. While this is only one of several concerns we have with the legislation, it is a significant issue for credit unions and can be a factor in our ultimate disposition toward this legislation.

We look forward to working with Chairman Dodd and the Banking Committee to address our concerns.